Delay condonation in tax appeals failed where no sufficient cause was shown and the main challenge remained maintainable.

A 2,249-day delay in filing appeals against proprietors, partners, brokers and bill issuers was not condoned because the Department gave no satisfactory explanation beyond a belated decision taken on counsel's advice. The earlier appeals against the manufacturers had already been filed in time, and the liability of the other noticees was only consequential to the finding against the manufacturers. Their omission from the later appeals did not undermine the maintainability of the Department's main appeals. No sufficient cause was shown for condonation, and no substantial question of law arose, so the delayed appeals were not entertained.

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Issues: Whether a delay of 2249 days in filing appeals against the proprietors, partners, brokers and bill issuers could be condoned, and whether omission to file such appeals had any on the maintainability of the Department's main appeals against the manufacturers.

Analysis: The Department offered no satisfactory explanation for the extraordinary delay, and the affidavit disclosed only a belated decision taken on the advice of counsel. The earlier appeals against the manufacturers had been filed in time, and the liability of the proprietors, partners and other noticees was only consequential to the finding against the manufacturers. Their omission from the later appeals did not affect the Department's substantive challenge in the main matters. In these circumstances, no sufficient cause was shown for condoning the delay, and no substantial question of law arose.

Conclusion: The refusal to condone the delay was upheld, and the Department's appeals were not entertained.

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